Odisha High Court

Aggregation of Multiple Deposits Determines Threshold for Mandatory Succession Certificate under RBI Claim Settlement Guidelines.

HEMANGINI MISHRA vs OMBUDSMAN OFFICER, C/O RESERVE BANK OF INDIA, BHUBANESWAR

Odisha High CourtJUDGMENT: June 22, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner is the widow of Abhiram Dash, who died intestate on January 12, 2025, leaving behind his wife, three daughters, and one son.

Source reference: para. 3

The deceased held three Fixed Deposits (FDs) totaling ₹36,56,313.62 (which grew to ₹37,30,606.06 by May 2025).

Source reference: para. 3, 11

Although all legal heirs executed claim forms and indemnity affidavits in favor of the Petitioner, the Bank (Opposite Parties 2 & 3) insisted on a succession certificate or letter of administration via a letter dated May 27, 2025.

Source reference: para. 4

The Petitioner’s grievance was rejected by the RBI Ombudsman on October 22, 2025.

Source reference: para. 5

The Petitioner approached the High Court seeking the release of funds without a succession certificate, arguing that each FD should be treated individually as being below the ₹15 lakh threshold limit.

Source reference: para. 10
02

Issues

1. Whether multiple fixed deposits held by a deceased depositor should be aggregated or treated individually for the purpose of defining the "threshold limit" under RBI guidelines for simplified claim settlement.

Source reference: para. 11, 19

2. Whether the Bank's insistence on a succession certificate for claims exceeding the threshold limit is legally sustainable when all legal heirs have consented to the payment via indemnity bonds.

Source reference: para. 12, 18
03

Law Applied

RBI Guidelines dated September 26, 2025, specifically Clause 10, which mandates a simplified procedure for claims below a "threshold limit" (defined as ₹15 lakhs for non-cooperative banks) and prescribes stricter documentation, including a Succession Certificate or Legal Heir Certificate with a third-party surety bond, for claims above the limit.

Source reference: para. 7, 11, 18

Section 370 of the Indian Succession Act, 1925, regarding restrictions on succession certificates.

Source reference: para. 13

Distinction of the precedent in Jhunu Choudhury v. Zonal Manager, Bank of India, where the claim was specifically found to be below the prescribed threshold.

Source reference: para. 15, 16
04

Reasoning

The court reasoned that the total claim amount (₹37,30,606.06) significantly exceeded the ₹15 lakh threshold limit defined in Clause 7(h) of the RBI Guidelines.

Source reference: para. 11

It rejected the Petitioner's argument for individual treatment of each FD, noting that the Petitioner applied for all deposits jointly through a consolidated claim, making the segregation of amounts impermissible.

Source reference: para. 19

Under Clause 10(b), when a claim exceeds the threshold, the Bank has the discretion to demand a succession certificate to ensure the safety of the settlement procedure.

Source reference: para. 18

The court found the Bank's procedure to be a safeguard for the interests of all legal representatives and not against public policy.

Source reference: para. 19

Furthermore, the court noted a technical defect: the Petitioner failed to challenge the specific order of the RBI Ombudsman.

Source reference: para. 20
05

Holding

The court answered that the aggregate amount governs the threshold limit and that the Bank is entitled to follow the stricter procedure under Clause 10(b) for high-value claims.

The court held that the Bank's insistence on a succession certificate was neither illegal nor unreasonable given the substantial amount involved and the presence of multiple legal heirs, and the Writ Petition was dismissed as being without merit.

Source reference: para. 19, 21
Odisha High Court

Original Court PDF

HEMANGINI MISHRAvsOMBUDSMAN OFFICER, C/O RESERVE BANK OF INDIA, BHUBANESWAR

Odisha High Court · June 22, 2026

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